by Thuy Dang
November 18, 2019
On November 8, 2019, the Philippines Department of Environment and Natural Resources (DENR) issued DENR Administrative Order (DAO) No. 2019-18, which outlines the requirements for the PMPIN exemption for importers and manufacturers whose polymers and polymers of low concern (PLC) are not yet listed on the Philippine Inventory of Chemicals and Chemical Substances (PICCS).
The DAO defines PLC as a polymer that must not be unstable, degradable, decomposed or depolymerized and meets either of the following conditions:
- The PLC’s Number Average Molecular Weight (NAMW) is at least 10,000 Da with less than 5% of oligomers with a Molecular Weight lower than 1,000 Da and less than 2% of oligomers with a Molecular Weight of lower than 500 Da. If the PLC is cationic, the Functional Group Equivalent Weight (FGEW) must be at least 5,000 Da.
- The PLC’s NAMW is between 1000 Da and 10,000 Da with less than 25% of oligomers with a Molecular Weight of lower than 1,000 Da, less than 10% of oligomers with a Molecular Weight of lower than 500 Da and no Reactive Functional Groups (RFGs) exceeding 2% by weight.
Along with the exemption of PLC, any polymers meeting at least one of the following criteria will not be required to go through PMPIN:
- All of the monomers are listed in the PICCS.
- Any non PICCS listed monomers and reactants such as crosslinking, chain transfer agents and post polymerization reactants that are less than 2% by weight.
- A new polymer if 2 or more of the top monomers by weight are covered under the definition of another PICCS listed polymer.
Although not required to go through PMPIN, the polymer importers and manufacturers must submit a Polymer Exemption application to the Environmental Management Bureau (EMB). The application must include the following documents:
- Polymer Exemption Form with notarization;
- Information of the polymer including chemical name and structure, CAS number (if available) and uses;
- SDS for the polymer or of the mixture/product containing the polymer;
- 100% composition of the polymer with CAS numbers for its monomers and other reactants;
- Data driven proof (GPC, IR spectroscopy, etc.) for meeting the exemption requirements;
- Confidential Business Information (CBI) request by submitting an official letter with justification;
- Processing fee of 1,500 PHP.
Upon receiving the complete application, the EMB will process within 20 working days. Please note that the exempted polymer will not be listed in PICCS.
Related Information – Drafts Open for Comment
The Philippines DENR and the EMB currently have several draft regulations available for pubic consultation:
- 3rd Revised Priority Chemical List (PCL) (on hold)
- Chemical Control Order for Cadmium and Cadmium Compounds
- Draft EMB Memorandum Circular (MC) for Inclusion of Distributors and Users on PCL Requirements
- Draft EMB MC on Philippines Inventor of Chemicals and Chemical Substances (PICCS) Certificate
- Chemical Control Order for Chromium VI and Chromium VI Compounds
- Guidelines on the implementation of GHS Classification and Labelling Requirements for Chemicals under IATA and IMDG
- Draft 2018 PICCS
- Clarification of Scope of PCL
Comments on the regulations can be submitted to the Environmental Management Bureau (EMB) via phone at (02)928-8892 or via e-mail at email@example.com
DENR Administrative Order (DAO) No. 2019-18 Polymers and Polymer of Low Concern (PLC) Exemption from Premanufacture and Pre-Importation Notification (PMPIN) Requirement http://chemical.emb.gov.ph/wp-content/uploads/2019/11/DAO201918Polymer.pdf
DENR and EMB draft regulations http://chemical.emb.gov.ph/
Philippines, PMPIN, Polymers
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